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Robert McClellon <br />October 8, 2014 <br />Page 4 <br />• If litter is distributed by the wind into trees and bushes on facility property or <br />adjoining properties, portable lifts may be employed to retrieve the litter. <br />• Portable litter vacuums may be used to collect litter that has accumulated on litter <br />fences. <br />• The main highway leading to the site will be routinely inspected for litter. If the <br />highway has litter associated with the trucks entering the facility, then the litter <br />will be picked up on a routine basis. All necessary safety precautions will be <br />followed. <br />• Before and after photos of any litter removal effort may be taken in the event <br />anyone questions the level of effort spent on litter collection. <br />• Site management's cell phone numbers along with the office number may be <br />provided to community/neighbors. <br />These measures should be included in the RCSI and the TPR. <br />III. Forward's Operations Have the Potential to Attract Birds and to Impact <br />Aircraft Safety. <br />As became clear during Forward's recent proposed landfill expansion process, the <br />landfill's proximity to the Stockton Airport has the potential to result in bird strikes. Bird <br />strikes could result in planes crashes, jeopardizing aircraft personnel and people on the <br />ground. The RCSI states that birds will be controlled through the litter collection system. <br />As discussed above, other than a reference to "daily litter collection," we can find no <br />evidence that a litter collection program exists at the Forward facility. <br />The RCSI also states that birds should not be a problem since wastes are processed <br />within 24 hours. As discussed above, the RCSI states that waste could sit unprocessed <br />for up to 48 hours. Unprocessed waste and failure to control litter could attract birds, <br />thereby threatening aircraft and public safety. <br />IV. Forward's Facility Has the Potential to Attract Vectors and Also Impact <br />Public Health. <br />In addition to gulls, refuse in landfills attracts vectors such as rats and moles. <br />Vectors can carry infectious pathogens, disease and parasites. See Landfill Expansion <br />Project Final EIR at IV.E-11. Neither the RCSI or the TPR contain provisions to ensure <br />that vectors are sufficiently controlled. We request that EHD require Forward to <br />implement a vector control program at its facility. <br />SHUTE, NIIHALY <br />,"~—WEINBERGERu_� <br />